New SEC Reporting Requirements for Conflict Minerals

Atlanta business litigation lawyer

Publically-traded companies are complying with new SEC requirements for reporting “conflict minerals.”  Securities and Exchange Commission (SEC) rules under the 2010 Dodd-Frank Act now require reporting of so called ‘conflict minerals,’ or compounds such as tin, gold, and tungsten in certain ‘Covered Countries.’  The Covered Countries include places where sales of these minerals may have been used to fund anti-Democratic political groups and promote human rights abuses, including the Democratic Republic of Congo and other nearby African nations.  For the first time, major companies like Apple, Google, and Deere & Co. are reporting that their products may contain these materials.  Many other publically-traded companies disclosed that they lacked the information to determine whether or not their products contained conflict minerals.


Known as 3TG minerals, these materials are common in electronics products.  According to Time, the SEC estimates that investigating supply chains for these conflict minerals will cost an estimated $200-600 million in the next few years. Ferreting out the origin of certain materials has proved complicated.  Time magazine quotes the Google SEC filing stating that, “based on our due diligence we have reason to believe that a portion of the 3TG used in our projects comes from the Covered Countries, but we have not identified any instances of sourcing that directly or indirectly supported conflict in the Covered Countries.”


Any publically traded company, particularly those in the high-tech or manufacturing sectors should be aware of these new requirements, and consider these requirements when sourcing materials.


When your business ventures require creative, proactive thinking, and analysis of complex issues, you can turn to James J. “Jim” Thomas II. Jim is ready to help Georgia businesses defend their business reputations and intellectual property rights with the latest business litigation tools. Jim has more than 35 years of courtroom experience in the Atlanta area, and can handle complex business litigation as well as analysis, evaluation, and resolution of existing and potential litigation. For a free consultation, email Jim, or give him a call at 404-869-5248, or go to

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